Memphis Comm. Sch. Dist. v. Stachura 477 U.S. 299 (1986)

U.S. Supreme Court

Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986)

Memphis Community School District v. Stachura

No. 85-410

Argued April 2, 1986

Decided June 25, 1986

477 U.S. 299

Syllabus

Respondent, a tenured teacher in the Memphis, Michigan, public schools, was suspended following parents' complaints about his teaching methods in a seventh-grade life science course that included the showing of allegedly sexually explicit pictures and films. While respondent was later reinstated, he, before being reinstated, brought suit in Federal District Court under 42 U.S.C. § 1983 against petitioner School District, Board of Education, Board Members, school administrators, and parents, alleging that his suspension deprived him of liberty and property without due process of law and violated his First Amendment right to academic freedom. He sought both compensatory and punitive damages. The District Court instructed the jury on the standard elements of compensatory and punitive damages and also charged the jury that additional compensatory damages could be awarded based on the value or importance of the constitutional rights that were violated. The jury found petitioners liable, awarding both compensatory and punitive damages. The Court of Appeals affirmed.

Held: Damages based on the abstract "value" or "importance" of constitutional rights are not a permissible element of compensatory damages in § 1983 cases. Pp. 477 U. S. 304-313.

(a) The basic purpose of § 1983 damages is "to compensate persons for injuries that are caused by the deprivation of constitutional rights." Carey v. Piphus,435 U. S. 247, 435 U. S. 254. The instructions at issue cannot be squared with Carey, or with the principles of tort damages on which Carey and § 1983 are grounded. Damages measured by the jury's perception of the abstract "importance" of a constitutional right are not necessary to vindicate the constitutional rights that § 1983 protects, and moreover are an unwieldy tool for ensuring compliance with the Constitution. Pp. 477 U. S. 305-310.

(b) Since such damages are wholly divorced from any compensatory purpose, they cannot be justified as presumed damages, which are a substitute for ordinary compensatory damages, not a supplement for an award that fully compensates the alleged injury. Pp. 477 U. S. 310-312.

(c) The erroneous instructions were not harmless error where the verdict did not specify how much of the compensatory damages was designed

Primary Holding

Compensatory damages are appropriate whenever a violation of constitutional rights causes actual, quantifiable harm, but they may not be measured according to the importance of the rights that have been violated.

Facts

A Memphis school district suspended a teacher, Stachura, from teaching because of his unconventional methods. He argued that the suspension violated his constitutional rights, and the judge instructed the jury to award compensatory and punitive damages in proportion to the significance of the rights that had been violated. The jury awarded both forms of damages to Stachura, and the award stood upon appellate review.

Opinions

Majority

Lewis Franklin Powell, Jr. (Author)

Warren Earl Burger

William Joseph Brennan, Jr.

Byron Raymond White

William Hubbs Rehnquist

John Paul Stevens

Sandra Day O'Connor

Jurors may not be asked to quantify the importance of constitutional rights, which are abstract concepts. The purpose of compensatory damages is to make the plaintiff whole after suffering quantifiable costs and losses.

Concurrence

Thurgood Marshall (Author)

William Joseph Brennan, Jr.

Harry Andrew Blackmun

John Paul Stevens

While he agreed with the outcome, Marshall felt uncomfortable with a section of Powell's opinion that suggested that Section 1983 claims can give rise to damages only for out-of-pocket injuries. This was inconsistent with his interpretation of the statute.

Case Commentary

This decision shows that there is no hierarchy of importance in constitutional rights, making some of them more significant than others.

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